Publications

: Client Update - New Planning Opportunities for ULCs

December 4, 2009

The Canada Revenue Agency (“CRA”) announced helpful administrative positions concerning the new rules under the Fifth Protocol to the Canada-US Income Tax Convention, 1980 which will come into effect on January 1, 2010. The CRA “Round Table”, held on November 24, 2009 as part of the Canadian Tax Foundation’s annual conference, provided a forum for CRA to provide its views on a variety of issues, including planning alternatives to manage certain changes under the Fifth Protocol.

For more information, please download a copy of this Client Update.

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